ML20141H896

Responds to Which Summarized Progress on Industry Proposed Reliability & Availability Data Collection Sys. Requests That NEI Continue to Maintain Awareness of Data Suitable for risk-informed Performance Based Regulation

ML20141H896
Person / Time
Issue date:	07/25/1997
From:	Jordan E NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Ralph Beedle NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
NUDOCS 9708010260
Download: ML20141H896 (2)

Text

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-/g k UNITED STATES j

NUCLEAR REGULATORY COMMISSION j n 2 WASHINGTON, D.C. 30eeHo01 1 ***** July 25, 1997

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Mr. Ralph E. Beedle, Senior Vice President Nuclear Energy _ institute

! 1776 Eye Street, N.W. i i

Suite 300 ,

j Washington, D.C. 20006-3706 '

Dear Mr. Beedle:

i f I am writing in response to your letter of March 21,1997 which summarized progress on an 2

industry proposed reliability and availability data collection system. The proposal included a ,

{ description of part of the Institute of Nuclear Power Operations' (INPO's) new Equipment *

Performance and Information Exchange (EPIX) system which replaces the Nuclear Plant  ;

Reliability Data System (NPRDS). It also indicated that (1) the system will continue to evolve '

i as feedback from end users is incorporated and (2) the industry is committed to work with the

! NRC staff to ensure that data requirements are addressed in the most practical and efficient i ,

manner. '

i-

! The NRC staff reviewed the proposal, including the information that will be available from EPIX and other sources. Other sources include INPO's Safety System Performance Indicator  ;

I (SSPI) system, where INPO and NRC are already sharing data, and Licensee Event Reports '

j and Monthly Operating Reports, which are provided directly to the NRC by licensees. On l l May 7.,1997, the staff recommended acceptance of this voluntary approach in lieu of rulemaking to obtain needed reliability and availability data (see Enclo'sure 1). On June 13,  !

1997, the Commission approved the staff's recommendation (see Enclosure 2). In addition, the Commission stated that the staff should:

1. Continue to work with industry to improve the content of the voluntary data {i.e ,

expand the voluntary program to minimize (a) the uncertainty in the data and (b) the use of compensatory measures to derive needed parameter estimates}. ,

2. Periodically advise the Commission on its efforts to work with industry to address shortfalls and limitations in the data, and advise the Commission on whether the )

voluntary approach remains a viable method of meeting regulatory needs. l 1

The NRC's Office for Analysis and Evaluation of Operational Data (AEOD) has responsibility l for coordination of data exchange activities with INPO AEOD will contact INPO and NEl to j initiate appropriate follow on activities and schedule a meeting in the near future. Mr. Patrick Baranowsky (301-415-7492) is the designated management contact and Dr. Bennett Brady (301-415-6363) is the technical coordinator for this effort. Followup activities that are currently needed include: (1) revising the NRC/INPO memorandum of agreement to address

/

sharing of EPIX data and (2) routine interaction of NRC and INPO in EPIX developmental j f)3 activities. We request that NEl continue to maintain awareness of this important effort for the voluntary approach to providing reliability and availability data suitable for risk-informed, k'Q6 /

performance based regulation.

'9708010260 970725

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PDR REVOP ER C 'f w w- I

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i I appreciate the participation by you and your associates at NEl that contributed to the I development of a cooperative arrangement to obtain and share reliability and availability l data. I believe the outcome serves the public, the indu<try and NRC in a practical and  ;

efficient manner, if you have any questions or comments, please let us know.

Sincerely, 1

Original Signed by I Edward L. Jordan  !

Edward L. Jordan l Deputy Executive Director  !

for Regulatory Effectiveness Enciosures:

1. SECY-97-101, dated May 7,1997, subject: Proposed Rule,10 CFR Section 50.76, l

" Reporting Reliability and Availability Information for Risk-significant Systems and  !

Equipment"

{

l

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2. Memorandum to L. Joseph Callan from John C. Hoyle, dated June 13,1997, subject: l Staff Requirements - SECY-97-101 - Proposed Rule,10 CFR Section 50.76,

" Reporting Reliability and Availability Information for Risk-significant Systems and Equipment" j cc: Mr. William G. Hastie, INPO Distribution:

RRAB RF PBaranowsky TOMartin SPD RF SMays JMitchell AEOD RF BBrady Central Files DHickman l EDO RF JRosenthat Public

• See previous concurrence:

DOCUMENT NAME: H OPA\7709NEl.let To receive a copy of this document, Indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE RRAS/RRAB l C SPD lC AEOD l EDqr'fkj~

f OGg)l EDO @

NAME DAllison CERossi Dross EL46fdan DV// LJCallse DATE 7/10/97* 7/10/97* 7/14/97* 7/y /97 7/% /97 7/2$ /97 OFFICIAL RECORD COPY

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POLICY ISSUE (Notation Vote)

May 7,'1997 SECY-97-101 FQ3: The Commissioners FROM: L. Joseph Callan l Executive Director for Operations

SUBJECT:

PROPOSED RULE,10 CFR SECTION 50.76, " REPORTING RELIABILITY AND i

AVAILABILITY INFORMATION FOR RISK-SIGNIFICANT SYSTEMS AND EQUIPMENT" PURPOSE:

To provide the Commission with the staff's recommendation for obtaining reliability and availability data for key safety systems.

BACKGROUND:

From 1991 to 1994, the Nuclear Regulatory Commission actively pursued with industry a voluntary system to obtain the reliability data needed for risk informed applications. These discussions were held first in meetings of a NRC/ industry task force that made recommendations to the Institute of Nuclear Power Operations (INPO) on revising the Nuclear Plant Reliability Data System (NPRDS) to obtain these data and later in meetings on a proposal by the Nuclear Energy Institute (NEI) that INPO's Safety System Performance Indicator (SSPI) data serve as a source of relietility and availability data. No action was taken on the recommendations to modify NPRDS to provide data for probabilistic risk assessment (PRA) applications. After failing to achieve a mutually acceptable program for providing reliability and availability data, on October 19,1994, James M. Taylor approved

Contact:

NOTE: TO BE MADE PUBLICLY AVAILABLE WHEN Dennis P. Allison, AEOD THE FINAL SRM IS MADE AVAILABLE (301) 415-6835 Y jy)lD

. l

' I

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l The Commissioners } l the initiation of rulemaking to require that licensees submit reliability and availability data to

. the NRC. In its directions to the staff in a staff requirements memorandum (SRM) dated j 4

October 24,1995, responding to SECY 95-215 and a SRM dated June 28,1995, '

j responding to SECY-95-129, the Commission (1) approved the proposed rule, and j (2) stated that the staff should continue to work with industry on voluntary submittal of i

reliability data, under a program that will meet the needs of all parties. The proposed rule  ;

j was published in the Federe/ Register for public comment on February 12,1996; the draft

regulatory guide was noticed for comment in the FederalRegister on May 2,1996; and a )

t

) public meeting was held on Jyne 4,1996.

I 4

As' discussed in the Statement of Considerations (SOC) for the proposed rule, the NRC needs a source of scrutable, plant-specific reliability and availability information to improve  !

l the NRC's oversight capability with respect to public health and safety by focusing the l l NRC's regulatory process in a risk-informed manner. Plant-specific reliability and availability information would be used in plant specific PRA models to develop indicators of i

plant performance that are more closely related to risk than those currently in use. Among j other benefits, these indicators would improve the process for selecting plants for focused attention at NRC senior management meetings. Plant-specific reliability and availability i data also would be used to guide plant inspections towards more risk significant systems "

i and components where their level of performance may be of concern. Credible reliability l 1 and availability data, collected in a database available to both NRC and the industry, would j also be used by licensees to implement several aspects of risk-informed regulation. These i

include applications for plant-specific licensing actions (e.g., technical specification l changes to address plant changes, risk ranking for graded quality assurance and risk-

! informed testing and inspection), in addition, the data would be useful to industry in the

, evaluation and goal setting activities of the maintenance rule and to the NRC in monitoring j maintenance rule implementation. Other uses of data discussed in the SOC include: (1)

! NRC staff reliability analyses of selected risk-significant systems and components, (2) l prioritizing generic safety issues and deciding whether new requirements are warranted to j

resolve the issues, and (3) improvements to NRC's plant-specific accident sequence i

precursor analyses.

j The public comment periods ended on June 11,1996, and July 5,1996, for the rule and i

the regulatory guide, respectively. Many public comments were received. Major issues i

include assertions in industry comments that: (1) costs are underestimated, (2) benefits I j are overestimated, (3) the rule would be overly burdensome, (4) the rule would be

l' premature, and (5) the rule is not needed.

I

In October 1996, INPO provided NRC a sample of SSPl data to evaluate a proposed  ;

voluntary alternative to the rule, and a revised Memorandum of Agreement (MOA) between i i INPO and the NRC was signed on December 24,1996 providing NRC with acc~ss to SSPI l j data. The revised MOA describes how INPO would provide SSPI data to the NRC, and the procedures and circumstances under which NRC could disclose data outside the NRC. On January 30,1997, the staff met with NEl, INPO, and industry personnel to discuss its I I

evaluation of the sample data. Aside from a few specific exceptions, the staff was unable I j to make meaningful estimates of demand unreliability or operating failure rates from SSPl i

data. However, SSPI does provide information for estimating unavailability. In response to

] that meeting, industry proposed making modifications to the INPO Equipment Performance 1

4 The Commissioners and information Exchange (EPIX) System to address issues raised by the staff. This new system will replace the NPRDS. Attachment 3 provides a summary of the suitability of the data from the voluntary proposal for estimating reliability and availability related parameters.

In a letter dated March 21,1997, Mr. Ralph Beedle of NEl provided additional information )

including a program description for EPIX. The letter indicated industry's commitment to l work with the NRC staff to ensure that data requirements are addressed in the most practical and efficient manner. In response to the issues identified at the January 30 meeting, EPIX would include additional information on demands and operating hours 'for ,

key components in systems within the scope of SSPl. j i

-The proposed voluntary alternative is based on the EPIX system which provides. component '

failure and demand data for a broad scope of systems and the SSPl system which provides train unavailability data ior systems within its scope. Attachment 1 provides a brief summary of the basic data that would be provided by industry under the voluntary alternative. The NRC staff would also use Licensee Event Reports (LERs) which provide actual and spurious demand data for engineered safety feature systems, monthly operating reports and other information to construct a more complete reliability database, available .

for general use. The staff has now completed its evaluation of the proposed voluntary l alternative to the rule as modified by the March 21,1997, letter from NEl.

DISCUSSION:

The staff considered two primary questions. The first involves the question of whether the voluntary approach is capable of providing the needed data. The second involves consideration of what action should be taken with respect to the rulemaking. The  !

following section discusses the advantages and disadvantages of the voluntary approach.

It forms the basis for resolving the first question by discussing how the voluntary approach l would meet the Commission's goals. The next section discusses how the staff might i proceed with respect to rulemaking in light of the advantages and disadvantages noted in the evaluation of the voluntary approach.

Staff Evaluation of the Voluntarv Anoroach in its evaluation, the staff considered a number of advantages and disadvantages of the proposed voluntary alternative, including cost, schedule, and other factors discussed below. The most important factor was to determine whether the reliability and availability parameters required in PRA models and applications can be estimated using the data supplied by industry under the proposed voluntary alternative along with other information available to the NRC. Attachment 2 identifies the PRA parameters and associated data elements. Attachment 3 shows the additional work the staff would need to do to construct a database that can be effectively used in risk applications. With the additional efforts noted in Attachment 3, the staff concludes that these parameters can be estimated and the NRC can construct a reliability database that reflects the parameters needed for effective use in risk informed applications. The NRC staff effort necessary to process the voluntary data into a coherent reliability and availability database is estimated to be about the same as for collecting and processing data under the proposed rule. The Office of l

e The Commissioners AEOD has budgeted this activity and in either case, would be responsible for its implementation.

There are three significant advantages to the voluntary approach: (1) lower cost for industry, (2) earlier data availability, and (3) industry support. Much of the information in EPIX (tracking component failures and estimating component demands) is designed to assist utilities in impismenting the maintenance rule. Thus, the staff estimates a relatively low additional cost to licensees if the NRC accepts the voluntary alternative. On the other hand, imposition of a rule, even a rule that is redrafted to minimize costs based on what is now known about SSPI and EPIX, would involve substantially greater costs. The difference is estimated to have a present value on the order of $50 million.

Voluntary data would be available earlier than data required by rule. Utilities began collecting data as of January 1,1997 to be put into EPIX when the software is available.

Voluntary data would be provided to NRC in early 1998. By contrast, the NRC would not receive data required by rule until mid-1999 at best (assuming six months to publish a final rule, six months to set up a program and begin collecting data, and one year to collect data

,for the first report). The voluntary alternative was proposed by industry representatives and would allow industry to use its preferred method of providing data and, thus, is considered to have industry support. Finally, the voluntary alternative is linked to the maintenance rule in that much of the data provided in EPIX has been designed to assist licensees in implementing the maintenance rule.

Also, under the voluntary proposal, data would be entered into a well-structured and efficient menu driven database system that should provide more consistent failure reporting than previously (i.e., in NPRDS). In addition, the voluntary alternative would provide component level failure reports for many more components than would be covered by the rule. Among other advantages of the increased number of failure reports is the larger population of data available for estimating common cause failure parameters which are a key influence on risk for highly redundant systems and components.

l The NRC staff will participate in the EPIX users group and will work with INPO to develop a system that will meet NRC and industry's needs for reliability data now and in the future.

The wluntary approach is expected to evolve as industry and the staff gain more experience in risk-informed applications. By contrast, a rule would need to be complete at the onset, or require rulemaking to make changes as experience is gained with risk-informed applications.

Now that the industry has offered to provide much of the needed data on a voluntary basis, the justification for a rule would need to rest on the incremental benefits of a rule vs a voluntary approach (rather than the total benefits as was the case at the proposed rule stage).'

At the proposed rule stage, the Offee of Management and Budget stated that (1) the proposed rule was not approved and (2) the NRC should address all of the public comments when it submits the foal rule.

The Commissioners l The key disadvantages to the voluntary alternative relate to (1) less specliic data than would be reported under the proposed rule and (2) less assurance of complete and accurate reporting. Information not currently specified in the EPlX system includes: (1) the number of valve-stroke tests vs valve flow tests, (2) the number of EDG manual starts (and manual loads) vs automatic starts (and automatic loads) and (3) the number of return-to-service tests vs other tests. For components in systems outside the scope of SSPl, planned unavailable hours will not be provided8 In addition, running hours for some components such as service water pumps and component cooling water pumps will be provided as one-time estimates. Although these data should be readily available, industry proposals have not included them in the voluntary approach.

Nonetheless, the staff has evaluated these limitations and has determined that methods are i available to overcome these problems and to make meaningful and reasonable estimates of the basic PRA parameters. Attachment 3 identifies the limitations in the voluntary data and compensatory measures. These would, necessarily, introduce some additional

. uncertainty and probably a conservative bias in some of the derived parameter estimates.

The NRC would work with INPO and industry representatives to improve EPIX in the future at more risk-informed applications that use the data are undertaken.

NRC's assurance of the quality and completeness of the data would be somewhat limited with the r*Jntary approach. In the past there have been performance problems with voluntar) s., liability data systems. However, the EPIX coupling to the maintenance rule and the highly structured nature of EPIX failure reporting provide some reason to expect a higher degree of completeness and accuracy in reporting.

The public availability of SSPI data (unavailability data) are covered by the December 24, 1996, MOA. The EPIX data are expected to be handled in a similar manner as NPRDS data covered by the MOA. That is, the plant specific raw data provided by industry would be publicly available only in specific circumstances such as a need to publish data in connection with a regulatory decision. However, analysis results, such as generic and plant specific equipment reliability estimates, based on the data can be made publicly available.

Staff Considerations Relatina to Rulemakina The staff considered several possible approaches with respect to rulemaking. These  ;

included (1) rejecting the voluntary approach and proceeding with rulemaking, (2) accepting the voluntary approach with different actions relating to rulemaking and (3) continuing discussion of the voluntary approach.

The Commission could completely reject the industry's proposed voluntary approach and go forward with the currently proposed rule, it should be recognized that the proposed rule provides a good definition of the data elements that are needed but does not 8

EPIX provides failures, estimated demands and unplanned unavailable hours, for structures, systems and components determined to be of hi0h safety signifcance in implementing the maintenance rule. but does not provide planned unavailable hours.

J

4 l The Commissioners -C 1

ericompass the full set of high safety significant systems as defined during implementation l of the maintenance rule. A variation would be to include data for additional systems

before completion of rulemaking. This modification might require another round of public 4

comment. Among other things, proceeding with rulemaking would delay the flow of reliability information that we expect to obtain from the voluntary approach, on the order of 1-2 years if the currently proposed rule is issued essentially as is or 2 3 years if the rule is modified to such a degree that another round of public comment is warranted.

1 The Commission could accept the industry's proposed voluntary approach, withdraw the '

proposed rule, evaluate the data as it accumulates, and work with industry to make l

, improvements over time. An alternative would be acceptance of the voluntary approach l on an interim basis, without withdrawing the proposed rule. If, after a 2 3 year trial period,  !

it is found that there are serious shortcomings in the voluntary approach, then the proposed rule would be revisited and converted to a final rule. This was considered but rejected because it was felt that there would be little salvage value to the proposed rule.

Undoubtedly any new rule would be so different in tone and content that it would be necessary to, in essence, start over and renotice the rule. Any required rulemaking is expected to be focused on the shortcomings experienced, and not on the predominant areas where the voluntary approach would be working.

Lastly, there is an option to reopen the discussions with industry. Under this option the Commission would neither accept nor reject the industry's proposed voluntary approach or i the rulemaking option. Instead, NRC staff would continue to interact with NEl and INPO to remedy some of the shortfalls discussed in the evaluation of the voluntary approach, such as the need for work arounds. This option was not pursued because the staff thought it would get a reasonable flow of vital information in a timely manner under the voluntary industry approach. The staff also believes that, as it works with the data, shortfalls and obvious inadequacies can be discussed with industry and changes and improvements can be obtained.

RESOURCES:

As previously stated, the NRC staff effort necessary to process the data into a coherent reliability and availability database is estimated to be about the same as for collecting and processing data under the proposed rule. AEOD's FY 1997 budget and FY 1998 budget request include sufficient resources to implement the actions discussed in this paper.

Resources for FY 1999 and beyond will be addressed during the upcoming budget  !

formulation process.

COORDINATION:

The Office of the General Counsel (OGC) has no legal objection to this paper. The Office of the Chief Financial Officer has no resource-related objection to this paper. The Office of the Chief Information Officer has reviewed this paper for information technology and information management implications and concurs.

l -

j The Commissioners -

i RECOMMENDATIONS:

The staff recommends that the Commission accept the voluntary approach proposed by NEl. The main advantages of the voluntary attemative (i.e., the cost, schedule, and l industry support), outweigh the disadvantages. As stated in the NEl letter of March 21, l 1997, "Given the evolving nature of industry data needs, continued dialogue with and feedback from NRC and industry users'are essentialin assuring the dynamic nature of EPlX as it effectively meets its specified needs.... The industry is committed to working with the NRC staff to ensure that data requirements are addressed in the most practical and efficient manner." The staff would continue to work cooperatively with INPO and industry representatives to improve the content of this voluntary data in the future. The staff plans i to negotiate appropriate revisions to the MOA to include EPIX data.

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.Jo tph Callan Exec ive Director for Operations Attachments:

1. Brief Summary of Data to be Provided by Industry Under the Voluntary Approach

2. Identification of PRA Parameters and Associated Data Elements

3. Evaluation of Reliability and Availability Information Comissioners' comments or consent should be provided directly to the Office of the Secretary by COB Friday, May 23, 1997.

Commission Staf f Office comments, if any, should be submitted to the Comissioners NLT Friday, May 16, 1997, with an information copy to the Office of the Secretary.

If the paper is of such a nature that it requires additional' review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

DISTRIBUTION:

Commissioners OGC OPA OCA CIO CFO EDO SECY I

_. _. _ _..._._ _._ _ _. . _ _ _ . . _ _ . . . . ~ _ - . . _ _ _ _ . _ _ . _ . . _ . .. _______ _

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g. .

4 BRIEF

SUMMARY

OF BASIC DATA PROVIDED BY INDUSTRY j UNDER THE VOLUNTARY APPROACH' i

i Data Needed Data Provided for Systems Data Provided for Other in SSPI Scope Systems of "High Safety l .

Significance" Under the

Maintenance Rule Failures Failures provided Failures provided Demands - Test Estimated average test Estimated average total demands demands (one-time estimate)

Demands - Non-Test Counted non test demands Demands by Type Not broken down into types Not broken down into types beyond test vs non-test at all Run Times Actual operating hours Estimated average operating hours (one time estimate)

Unplanned Unavailability Unplanned unavailable time Unplanned unavailable time for each repair 2 for each repair Planned Unavailability Planned unavailable hours for No train for each month (from SSPI)

Unavailability Due to Unavailable hours for each EPIX provides unolanned Support System train for each month (from unavailable times directly SSPI) for components in support systems, but not planned unavailable hours Concurrent Unavailability Ability to screen for No significant occurrences Unless otherwise noted, data are provided by EPIX on a component basis.

2 From time of failure discovery to time of return to service.

Attachment 1

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s f- .

o IDENTIFICATION OF PRA PARAMETERS AND ASSOCIATED DATA ELEMENTS 1

The followina PRA eauations indicate the parameters that need to be estimated:

1 l

l

• Equation for the total unavailability of standby equipment.

! Or = q, + M A,t, + U t

i

where

q, n demand failure probability (failure to start or change state)

!  % A ,t, = equipment unavailability due to failure from environmental s stresses -

l U = equipment unavailability due to out of service for repair or

! maintenance

! t, = test interval i~

• For operating equipment such as pumps, EDGs, or control valves, a term is added to

! the equation to represent failure during the mission time l O(t) = 1 - e **

l where: Atr) = the running, or operating, failure rate

t(m) = the mission time 4

1 l Data from a reliability database are needed to estimate q,, A , U, and A(r). The l terms t, and t(m) are unique for each application, and are determined by plant j operations and design characteristics.

l To estimate 4, the number of failures to start or change state (N,) and the i

! number of demands on the component to start or change state (N,) are i needed.

q, = N, / N, i To estimate A., the number ofiailures due to environmental stresses (N,,)

I and the component on-line time (t,) are needed. l A, = N,, / t, To estimate U, the planned outage time (t.), the unplanned outage time (t ), and the component time on line (t,) are needed.

U = (t, + t ) / t, To estimate A(r), the number of failures during operation, or while running (N,,), and the accumulated run time (t,) are needed.

A(r) = N,, / t, 1 Attachment 2

_- . . - , . - . - . _ ~ . . - . - - . - - . _ - . . ~ . . _ . . . . - . . . . . . _ _ . . - . - - . . - - . . . . - . . - - -... . -

l EVALUATION 'OF REllABILITY AND AVAILABILITY INFORMATION  !

i The followina table indicates the kinds of efforts needed to compensate for weaknesses in the voluntary data in estimatina PRA i parameters:

PRA PARAMETERS AVAILABILITY UNDER VOLUNTARY POSSIBLE WORK-AROUNDS y APPROACH j

N,(The number of PRA Available in EPIX on a component basis, No work-arounds needed. i failures, needed as the includmg the 5p66k type of demand i numerator to estimate g) assocefed with the fa#ure.

N, (The number of valid For components in the SSPI reportmg scope, Work-around for SSPl scope components i demands, needed as the EPIX will contain total component level involves obtaining further breakdown of demand i denominator to estimate g) demands partitioned as " test" (estimated) type data by:

and "non-test" (counted). -

estimating test demands from Tech Specs IST requirements and other requirements 1 estimating actual and spurious demands from LERs .

comparing with demands in EPIX f

For components not in SSPl scope. EPIX will Work-around for non-SSPl components involves contain component level demands, not estimating demands as above, and comparing

partitioned by type, and estimated once. with EPIX estimates.

N, (the number of PRA Failures available in EPlX on a component No work-arounds needed.

failures due to basis usmg cause coding and supplemental environmental stress, descriptions needed as the numerator to estimate A,)

l t, (Component standby The plant state is recorded for all failures in No work-arounds needed.

on-line time, needed to EPIX. Other sources available to the NRC estimate component failure (e.g. monthly operating reports) provide the rate A ) plants' operational states.

1 Attachment 3

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. . . . . . _ _ . _ . _ _ _ . - _ . . . - - . _ - - _ . - . _ _ ... _ - _ . . ~ - . _ . . . _ - - - - - - . . _ . . . _ . . - - _ _ . - . . ~

PRA PARAMETERS AVAILABILITY UNDER VOLUNTARY POSSIBLE WORK-AROUNDS ,

-APPROACH N,,(Number of component EPIX contains component level failures No work-arounds are needed.

failures during component recorded against the discovery method, operation, needed to including those discovered while running, for ,

estimate the component all components of interest.

operating failure rate, A(r))

t,(Operating time for EPIX contains component level operating For SSPI-scope components, no work-arounds rotating equipment and time, counted for components in the SSPI needed.

control valves, needed to scope. i estimate the component operating failure rate A(r))- r7 >

For non-SSPI components, EPIX provides For non-SSPI components, the staff will use one-time estimates of operating time. Information from LERs and testing inforrnation (Tech Spec, IST) and operating failure rate data from similar components. The estimates are a expected to contain more uncertainty than the axanted values discussed above.

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I PRA PARAMETERS AVAILABILITY UNDER VOLUNTARY POSSIBLE WORK-AROUNDS i

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APPROACH 4

Concunent train unavailable SSPI currently collects unavailable hours on For SSPI-scope trains, no work-arounds are hours a monthly basis. For the systems in SSPI needed.

scope, this provides sufficient information to identify potential concurrent outages for further investigation.

For Non-SSPI systems, EPIX does not For non-SSPI components, concurrent '

~

directly provide component or train unavailable hours cannot be estimated since i concurrent outage information. planned maintenance outages are not recorded i in EPIX. Some instances will meet LER reporting requirements.

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.. Action: Ross, AE0D/

//* **%,'q' , , , UNITED 5TATES .

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j NUCLEAR REGULATORY COMMISSION wasusworow.o.c.zosss Callan Jordan Thompson

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• e . * * /, Norry June 13, 1997 orrect or var Blaha saca TAny Lieberman, OE Collins, NRR Halman, ADM Allison._AEOD Shelton, IRM MEMORANDUM TO: L. Joseph Callan Meyer, ADM Exec tive D rector for Operations FROM:

Jo .

oyl , Secretary 4

SUBJECT:

STAFF REQUIREMENTS - SECY-97-101 - PROPOSED 1

RULE,'10 CPR SECTION 50.76, " REPORTING RELIABILITY AND AVAILABILITY INFORMATION FOR RISK-SIGNIFICANT SYSTEMS AND EQUIPMENT" The Commission has approved the staff's recommendation to accept the voluntary approach proposed by NEI for obtaining reliability

and av'.ilability data for key safety systems.

The staff should continue to work with industry representatives to improve the content of the voluntary data. These improvements should seek to expand the voluntary program to minimize 1) uncertainty in data and 2) the use of compensatory measures to derive needed parameter estimates. The staff should periodically update the Commission on its efforts to work with industry to address shortfalls and limitations in the data, and advise the Commission on whether the voluntary approach remains a viable method of meeting regulatory needs. ~his periodic update may be incorporated, Appropriate, in the quarterly updates to the PRA implementation plan.

l (EDO) (AEOD/RES) (SECY Suspense: 9/26/97) 9500047, RES SECY NOTE: THIS SRM, SECY-97-101, AND THE COMMISSION VOTING RECORD CONTAINING THE VOTE SHEETS OF ALL-COMMISSIORRS WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS SRM.

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cc: ' Chaiman Jackson '

Commissioner Rogers Commissioner Dicus Connissioner Diaz 'l Commissioner McGaffigan .

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CIO CFO 1

OCA OIG j

Office PDR Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)

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